Trinidad v.
CA
NATURE: Action for Partition- Petition for review on certiorari of CA’s decision on reversing the trail
court’s decision.
LC’ DECISION: Ruled in favor of the plaintiff, stating that he is entitled to inherit the property left by
his deceased father Inocentes Trinidad.
FACTS: Patricio Trinidad and Anastacia Briones were the parents of 3 children, namely, Inocentes,
Lourdes and Felix. When Patricio Trinidad died, he left 4 parcels of land.
Arturio Trinidad claims to be the legitimate son of Inocentes. He then demanded from the defendants to
partition the land in 3 equal shares and to give him the 1/3 share of his late father. The defendant refused.
Evidences presented by Arturio:
a. Gerardo and Meren testified that Inocentes and Felicidad Molato are the parents of Arturio; that
Felix and Lourdes as the uncle and aunt of Arturio; and also identified pictures where the
respondents were with Arturio and his family. They also state that Inocentes and Felicidad were
married, by a protestant pastor by the name of Lauriano Lajaylajay.
b. Arturio, himself, was presented as witness. He showed a certificate of baptism, and
a certificate of loss issued by the Civil Registry that his birth certificate was burned during World
War 2. He also testified that he lived with Felix and Lourdes and provided for his needs.
Lourdes contented the following:
a. Pedro Briones and Beatriz Sayon, both cousins of the defendant, who testified that Inocentes was
never married.
b. Lourdes Trinidad also testified that she was not aware that his brother married anybody and
denied that Arturio lived with them.
ISSUE: Whether or not the petitioner presented sufficient evidence of his parent’s marriage and his
filation. (YES)
RULING: Petition granted CA’s decision reversed.
RATIO: The Court ruled that although the marriage contract is considered the primary evidence of the
marital union, petitioner’s failure to present it is not proof that no marriage took place, as other forms of
relevant evidence may take its place.
The court ruled that other forms of relevant evidence may take its place such as: the testimony of a
witness to the matrimony, the couple’s public and open cohabitation as husband and wife after the alleged
wedlock, the birth and the baptismal certificates of children born during such union, and the mention of
such nuptial in subsequent documents. In this case, petitioner was able to present such substitute
evidences.
With regard to his filiation the absence of birth certificate any other means allowed by Rules of Court &
Special Laws are acceptable. Also the use of Arturo of his father’s surname without objection from
private respondents. Indicates a presumptive proof of his status as Inocentes' legitimate child.